Prevention a key focus of Conflict of Interest Act’s administration: 2021-2022 annual report

The Office’s ongoing focus on prevention was reflected across a range of activity areas. It ​guided 352 newly appointed or reappointed reporting public office holders through the initial compliance process, positioning them to prevent conflicts of interest going forward. It conducted over 1,100 annual reviews of their information and responded to over 3,300 requests for advice from public office holders, up 50% from the year before. 

Reflecting one of its strategic priorities, in 2021-2022 the Office started implementing a preventative approach to compliance assurance. It involves continuing to give public office holders proactive guidance, offering annual training for those in certain positions so they can better identify potential conflicts of interest, and identifying new monitoring tools. 

The Office increased its education and outreach activities to help public office holders understand the rules so they can prevent conflicts of interests. It gave 19 presentations to offices and organizations with regulatees subject to the Act, almost twice as many as the previous year. It also issued an updated information notice on reimbursement of costs associated with divestment of assets and withdrawal from activities, and an information notice on the meaning of “friendship” for the purposes of the Act. The Office conducted its first-ever survey of public office holders and is using the results to further strengthen outreach activities. It also expanded its public communications, tweeting 159% more times than in the previous year, and fielded nearly 3,500 information requests from the media and members of the public, up 66%. 

While targeting prevention, the Office also continued to enforce the Act as necessary. It issued 18 administrative monetary penalties and 15 compliance orders, both up from the year before. It reviewed 33 concerns about possible contraventions of the Act, fewer than in the previous year, and issued two examination reports: the Trudeau III Report and the Morneau II Report. 

The Commissioner appeared before the House of Commons Standing Committee on Access to Information, Privacy and Ethics, which has oversight responsibility for the Office and reviews its annual spending estimates and matters related to the Commissioner’s reports under the Act. ​

“Prevention—recognizing and taking measures to avoid conflict of interest situations—is the major focus of the Conflict of Interest Act. This was reflected in the Office’s work in 2021-2022, as it has been in previous years. We helped reporting public office holders achieve and maintain compliance with the Act by meeting its requirements, gave them direction and advice, and conducted education and outreach activities.” 

“What’s new on the prevention front is the approach to compliance assurance that we adopted as part of the Office’s 2021-2024 strategic plan. We’re being more proactive in giving public office holders direction on issues that involve real or potential conflicts of interest. We’re giving those in positions that have been evaluated as potentially having a higher risk of conflict of interest, such as ministers, parliamentary secretaries, heads of agencies and deputy ministers, more training opportunities to help them identify potential conflicts of interest. And we’re identifying new tools to help detect compliance issues, at-risk activities and areas that could raise concerns.” 

“Public office holders are accountable for their compliance with the Conflict of Interest Act, so it’s up to them to learn the rules and understand their obligations. The Office provides tools to help them do that, including virtual and in-person educational sessions and helpful information posted on its website. Plus, advisors in the Office are always available to give public office holders guidance and direction and answer any questions they may have.”​